Codes of Ethics of Two Banks

In order to best fulfill the goals of the company's code of ethics, it is important for the code to be credible. A code's credibility is derived largely through proper formation and implementation. The code of ethics for National City is administered and monitored by the Human Resources (HR) Department. The HR Department requires employees and officers to affirm compliance with the code of ethics every two years by completion of a signed certificate of compliance. The fact that each employee and director of the bank signs and updates an agreement of compliance adds credibility to the code: each employee knows that the code applies to everyone there and no employee can excuse his or her actions through ignorance of the code. It is important to note that officers of the bank are held to the same ethical standard as the employees, further encouraging everyone to follow the code. National City ensures that its code is circulated to all of its employees through publishing the code of ethics on the company's website and by publishing it in the employee handbook.

Huntington Bank's code is administered by the legal department, which may add a level of seriousness for employees. Unlike National City's code, Huntington 's does not lay out specific methods of distribution or endorsement. The code requires that employees follow it, but it does not explain where employees will find the code or whether they must sign a certificate regarding their intentions to follow the code. Huntington requires that all employees and members of Boards of Directors comply with the code, which is similar to National City Bank's broad application of the code. Again, endorsement of the code by directors and officers may increase the seriousness of the code among all employees.

National City's Code of Ethics has the strength of including provisions that require employees to reaffirm their understanding of the code every two years. This requirement ensures that each associate is reminded of the policies and procedures on an ongoing basis. The Huntington code could be improved by including specific distribution and contractual provisions.

While the National City code is administered by the HR department, Huntington's is administered by the legal department. There are pros and cons to each department as the administrator: the legal department may add a sense of seriousness to the code while the HR department may make the code seem more broad and far-reaching. Huntington's code includes explicit instructions on how to act in a positive way, rather than just prohibitions. By including details on how to comply with the code, Huntington provides better information to its employees.

Both codes could be improved with a preamble that explains how the code was developed, how to suggest changes to the code, and who was involved in the code's development and maintenance. This information would add credibility to the codes. Additionally, both codes would be helped by endorsements by officers and directors.